Legal Opinion
Tribune Publishing Company v. United States
Court of Appeals for the Ninth Circuit
Decided January 6, 1988No. 86-3734, 86-3987 and 86-3988PublishedCited by 14 opinions
1Opinion of the Court
NORRIS, Circuit Judge:
This case involves the tax treatment of settlement proceeds of securities fraud litigation arising out of an I.R.C. § 368 tax-free reorganization. 1
I
In 1969, Tribune Publishing Co. (Tribune), the taxpayer, owned 6,109 shares, or 7.1 percent, of the outstanding stock of West Tacoma Newsprint Co. (Newsprint), a producer of newsprint. Tribune’s basis in the stock was $619,462. That year, Newsprint was acquired by Boise Cascade Corp. (Boise Cascade) in a tax-free reorganization —specifically, a merger within the scope of I.R.C. § 368(a)(1)(A). Tribune received 41,-476 shares…
2Cases cited10 opinions
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- Burnet v. LoganSupreme Court of the United States · 1931
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Megargel v. CommissionerUnited States Tax Court · 1944
5 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Jean Ronald Getty Karin Getty v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1990
- Franklin P. Coady Nona Coady v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Milenbach v. CommissionerUnited States Tax Court · 1996
- Exxon Corp. v. Oklahoma Tax CommissionCourt of Civil Appeals of Oklahoma · 1993
- Murphy v. Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2006
9 more not listed; retrieve them via the Exa API.